The Internal Revenue Service plans to deploy thousands of new hires to expand audits of partnerships and high net wealth individuals. As part of a larger transformation at the agency, it is using some of the $60 billion in...more
11/14/2023
/ Artificial Intelligence ,
Audits ,
Digital Assets ,
Estate Planning ,
Generation-Skipping Transfer ,
IRS ,
Partnerships ,
Regulatory Reform ,
Tax Reform ,
Wealth Management ,
Wealth Tax
Boards routinely confront an array of difficult issues. In this issue of The Informed Board, we tackle four of the thorniest and most topical:
- How to preserve the integrity of a deal process where a key fiduciary (say,...more
11/9/2023
/ Acquisitions ,
Artificial Intelligence ,
Board of Directors ,
Corporate Governance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Federal Trade Commission (FTC) ,
Fiduciary Duty ,
Information Sharing ,
Internal Investigations ,
Investment ,
Investors ,
IRS ,
Merger Controls ,
Mergers ,
Partnerships ,
Shareholders ,
Wealth Tax
On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more
9/13/2023
/ Enforcement Actions ,
Estate Planning ,
Inflation Reduction Act (IRA) ,
Investment Management ,
IRS ,
Offshore Funds ,
Partnerships ,
Private Equity ,
TEFRA ,
Trustees ,
Wealth Tax
On June 21, 2023, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published proposed regulations (88 FR 40528 and 88 FR 40496) under two key provisions of the Inflation Reduction Act of 2022 (IRA)...more
On November 16, 2022, the IRS released a long-awaited update to the procedure for large corporate taxpayers and large partnerships under continuous audit to obtain Qualified Amended Return (QAR) treatment for items disclosed...more
The Treasury Department and the Internal Revenue Service (IRS) recently released long-awaited proposed regulations regarding the carbon capture and sequestration tax credit provided under Section 45Q of the Internal Revenue...more
The Internal Revenue Service (IRS) recently released Notice 2020-41 (the Notice), providing important relief with respect to the beginning-of-construction requirement for the production tax credit (PTC) and the investment tax...more
5/29/2020
/ Begun Construction Test ,
Construction Project ,
Coronavirus/COVID-19 ,
Delays ,
Investment Tax Credits ,
IRS ,
Physical Work Test ,
Popular ,
Production Tax Credit ,
Relief Measures ,
Renewable Energy ,
Safe Harbors ,
Solar Energy ,
Wind Power
On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more
3/22/2017
/ 1099s ,
Board of Directors ,
Breach of Duty ,
Class Action ,
Corporate Taxes ,
Derivative Suit ,
Dodd-Frank ,
False Claims Act (FCA) ,
Federal v State Law Application ,
Form 1098-T ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Inversion ,
IRS ,
Misrepresentation ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Litigation ,
Shareholder Litigation ,
Stock Drop Litigation ,
Tax Litigation ,
Tax Planning ,
Whistleblowers
The Internal Revenue Service (IRS) has released welcome new guidance with respect to renewable electricity production and energy investment tax credits. A notice issued on May 5, 2016, reflects changes to the production tax...more
Legislation enacted in November 2015 will fundamentally change the way the Internal Revenue Service (IRS) examines entities treated as partnerships for U.S. federal tax purposes, including how it assesses and collects tax...more
On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more
11/5/2015
/ Administrative Procedure Act ,
Audits ,
Barack Obama ,
Bipartisan Budget ,
Burden of Proof ,
Business Taxes ,
C-Corporation ,
FPAA ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
K-1 ,
New Legislation ,
Partnership Interests ,
Partnerships ,
S-Corporation ,
Statute of Limitations ,
Tax Assessment ,
TEFRA ,
Treasury
The Internal Revenue Service (IRS) has released welcome new guidance on renewable electricity production and energy investment tax credits. A notice issued on August 8, 2014, addresses when a facility or equipment maintains...more
On June 19, 2014, the U.S. Supreme Court in United States v. Clarke1 held that a taxpayer has a right to conduct an examination of IRS officials regarding their reasons for issuing an administrative summons when the taxpayer...more
In United States v. Woods,1 the U.S. Supreme Court ruled unanimously for the government on two long-brewing disagreements over penalty jurisdiction in the partnership context and over the breadth of valuation misstatement...more
On November 4, 2013, the Internal Revenue Service released an internal directive that completes a two-part process of reshaping the dynamic between taxpayers and IRS examiners during the information-gathering phase of an...more
On April 15, 2013, the Internal Revenue Service released Notice 2013-29 (Notice), which established guidelines and a safe harbor to determine when construction has begun on a “qualified facility” for purposes of the renewable...more